`Patent Owner’s Objections to Evidence
`Filed on behalf of Patent Owner Genentech, Inc. by:
`
`David L. Cavanaugh (Reg. No. 36,476)
`Rebecca A. Whitfield (Reg. No. 73,756)
`Robert J. Gunther, Jr. (Pro Hac Vice to be filed)
`Lisa J. Pirozzolo (Pro Hac Vice to be filed)
`Kevin S. Prussia (Pro Hac Vice to be filed)
`Andrew J. Danford (Pro Hac Vice to be filed)
`WILMER CUTLER PICKERING
` HALE AND DORR LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`
`Adam R. Brausa (Reg. No.
`60,287)
`Daralyn J. Durie (Pro Hac Vice to be
`filed)
`Durie Tangri LLP
`217 Leidesdorff Street
`San Francisco, CA 94111
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CELLTRION, INC.,
`Petitioner,
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`v.
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`GENENTECH, INC.,
`Patent Owner.
`
`Case IPR2017-01374
`U.S. Patent 6,407,213
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64
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`Pursuant to 37 C.F.R. § 42.64, Patent Owner Genentech, Inc. presents the
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`IPR2017-01374
`Patent Owner’s Objections to Evidence
`
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`following objections to evidence served with the Petition of Celltrion, Inc.
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`(“Petitioner”).
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`Genentech objects to Exhibit 1003, Declaration of Declaration of Dr. Lutz
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`Riechmann, Ph.D., in Support of Celltrion’s Petition for Inter Partes Review of
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`U.S. Patent No. 6,407,213. Genentech specifically objects to ¶¶ 26, 27-36, 44-45,
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`47, 51-53, 60-61, 74, 79, 82-86, 88, 91-93, 97, 99-110, 114, 116, 118-120, 123,
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`128, 132, 145-150, 152-153, 155-156, 158-160, 162-164, 167-174, 176, 178-187,
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`189-192, 194-195, 197-207, 209, 211-213, 215-222, 224-234, 236-240, 242-270,
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`272-277, 279-282, 284-300, 302-306, 308-312, 314-317, 320-353 and all
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`paragraphs that rely on those paragraphs as lacking a disclosed basis of sufficient
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`facts or data (FRE 705; 37 C.F.R. § 42.65), not being based on sufficient facts or
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`data, the product of reliable principles and methods, and/or a reliable application of
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`the principles and methods to the facts (FRE 702, 703), and being misleading
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`and/or confusing (FRE 403).
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`Genentech objects to Exhibit 1004, Declaration of Dr. Robert Charles
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`Fredrick Leonard, M.D., in Support of Celltrion’s Petition for Inter Partes Review
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`of U.S. Patent No. 6,407,213. Genentech specifically objects to ¶¶ 13-14, 16, 24-
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`25, 38-40, 48, 56, 60, 62-64 and all paragraphs that rely on those paragraphs as
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`lacking a disclosed basis of sufficient facts or data (FRE 705; 37 C.F.R. § 42.65),
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`not being based on sufficient facts or data, the product of reliable principles and
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`IPR2017-01374
`Patent Owner’s Objections to Evidence
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`methods, and/or a reliable application of the principles and methods to the facts
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`(FRE 702, 703), and being misleading and/or confusing (FRE 403).
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`Genentech objects to Exhibit 1030 Protein Data Bank - Chronology,
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`National Science Foundation,
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`https://www.nsf.gov/news/news_summ.jsp?cntn_id=100689 (last accessed April
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`12, 2017) as lacking proper authentication (FRE 901).
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`Genentech objects to Exhibit 1039 SEER Stat Fact Sheets: Breast Cancer,
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`National Cancer Institute,
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`http://seer.cancer.gov/statfacts/html/breast.html (last accessed March 17,
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`2017) as lacking proper authentication (FRE 901).
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`Genentech objects to Exhibit 1129 Excel Trick, History of Microsoft Excel
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`1978–2013,
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`http://www.exceltrick.com/others/history-of-excel/ (last accessed April 13,
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`IPR2017-01374
`Patent Owner’s Objections to Evidence
`
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`2017) as lacking proper authentication (FRE 901).
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`Respectfully submitted,
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`Date: December 15, 2017
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`
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`/David L. Cavanaugh/
`David L. Cavanaugh
`Registration No. 36,476
`Counsel for Patent Owner
`
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`WILMER CUTLER PICKERING HALE AND DORR LLP
`1875 PENNSYLVANIA AVENUE NW
`WASHINGTON, DC 20006
`TEL: 202-663-6000
`FAX: 202-663-6363
`EMAIL: david.cavanaugh@wilmerhale.com
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`IPR2017-01374
`Patent Owner’s Objections to Evidence
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`CERTIFICATE OF SERVICE
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`I hereby certify that, on December 15, 2017, I caused a true and correct copy
`of the following materials:
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`
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` Patent Owner’s Objections to Evidence
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`to be served via electronic mail on the following attorneys of record:
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`Cynthia Lambert Hardman
`GOODWIN PROCTER LLP
`chardman@goodwinlaw.com
`620 Eighth Avenue, New York, NY 10018
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`Robert V. Cerwinski
`GOODWIN PROCTER LLP
`rcerwinski@goodwinlaw.com
`620 Eighth Avenue, New York, NY 10018
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`/Vera A. Shmidt/
`Vera A. Shmidt
`Reg. No. 74,944
`Wilmer Cutler Pickering Hale and Dorr LLP
`60 State Street
`Boston, MA 02109
`(617) 526-6137
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